Legislation reshapes U.S. taxation of cross-border payments, modifies withholding and surtax structures, and eliminates key thresholds under prior law. Attendees will learn how these reforms alter planning for corporations, partnerships, trusts, and exempt organizations with international exposure. The program will highlight the expanded surtax on certain foreign payments, the interaction of OBBBA provisions with the Base-Erosion and Anti-Abuse Tax (BEAT), and the compliance impact on U.S. companies with foreign shareholders. Practitioners will gain insight into exceptions for U.S. multinationals and funds, as well as the broader risks and reporting obligations created by the new law.
Course ID: OBIN
What H.R.1, “OBBBA” (Commonly Known as “The Big Beautiful Bill Act”) Means for You and Your Clients: International Tax Update
Learning Objectives
After completing this course, you will be able to:
- Identify how OBBBA expands surtaxes on U.S. payments to foreign recipients
- Recognize the elimination of gross receipts and base erosion thresholds under prior law
- Apply the revised rules to U.S. corporations with majority foreign ownership
- Determine when the Majority U.S. Owner Exception applies
- Assess how partnerships, trusts, and private foundations are impacted by new surtax provisions
- Evaluate planning considerations under the modified BEAT framework
- Assess and prepare to advise clients on compliance and reporting obligations created by the new law
- Identify risks and opportunities for U.S. multinationals and investment funds
Major Topics
- OBBBA surtax on foreign payments (IRC §899)
- Increased withholding and gross-basis tax rates on U.S.-sourced payments
- Removal of $500M gross receipts and 3% base erosion thresholds
- Application to U.S. corporations, partnerships, trusts, and private foundations
- Interaction with Base-Erosion and Anti-Abuse Tax (BEAT)
- Majority U.S. Owner Exception for U.S. multinationals and funds
- Compliance requirements and reporting risks
- Planning implications for cross-border transactions
Advanced Preparations
None
Who Should Attend
CPAs, EAs, tax professionals
Fields of Study
TaxesPrerequisites
Basic understanding of federal individual and estate tax law